ML19270G844
| ML19270G844 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 04/25/1979 |
| From: | Onsdorff K NEW JERSEY, STATE OF |
| To: | |
| References | |
| NUDOCS 7906200611 | |
| Download: ML19270G844 (4) | |
Text
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MN NRC pURLIC DOCUMryf H003f
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OUTLINE OF INTERVE!DPS, 6
pj COLEES, CPDSS-EWIINATION D
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ap CONTENTIONS 'IVO AND SIX b
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2.
The licensee has given iradequate consideration to the occurrence of accidental criticality due to the increased density or ccnpaction of the spent fuel assccblies. Additional consideration of criticality is required due to the following:
A.
deterioration of the neutron absorption material provided by the Boral plates located between the spent fuel bundles; B.
deterioration of the rack structure leadirs to failure of the rack and consecuent dislodging of spent fuel bundles.
6.
The licensee has given iradecuate consideration-to cualificatien and testing of Boral material in the enviror;r.ent of protracted association with spent nuclear fuel, in order to validate its continued prcoerties for reactivity control and integrity.
I.
The Potential for the Occurrence of Accidental Criticality in the Spent Fuel Pool and failure of the reactivity and structural surport fixtures in the spent fuel pool to reet design specifications.
A.
Deterioration of the neutron absorption reaterial in che
") ' 11 74 g fuel racks.
L-SU LIJ 1.
Cross-exa.-tination of ?BC staff.and PSE&G Co. witnesses shall address the ecmputational analysis performed on the ccroact rack configuration to verify ccmoliance with the criticality Keff, of 0.95 (estirated time of cross-examination:
3 hrs.)
79062004//
forthwith to resolve the problern without vitiating the integrity of the reactivity control and structural support fixtures in the spent fuel pool (estimated time of cross-examination:
3 hrs.)
IDER ALIDRAYS CREEK 'IU,03 HIP CONTEhTION LUIEER ONE 1.
'Ihe Licensee has not considered in sufficient detail possible alternatives to the proposed expansion of the spent fuel pool. Specifically, the Licensee has not established that spent fuel cannot be stored at another roactor site. Also while the GES:D proceedings have been termirated, it is not clear that the spent fuel could not by scm2 arrangement with Allied Chemical Corp. be stored at the AGNS Plan in Barnwell, South Carolina. Furthermore, the Licensee has not explored nor exhausted the possibilities for disposing of the spent fuel outside of the U.S.A.
I.
Inadeqtate Consideration by the hTC Staff and Utility of Viable Alternatives to the propsed High Density Paracking of the Salem One Nuclear C2nerating Statior Spent Fuel Pool.
A.
Use of storage capacity available at existing Away From Reactor (AFR) reprocessing plants (30 minutes).
B.
Construction of new AFR storage capacity at isolated, unpopulated areas of the United States (30 minutes).
C.
Storage of spent fuel generated at Salem One Nuclear Generating Station at other active or deconmissioned nuclear reactor sites (30 minutes).
D.
Slow down or cessation of spent fuel generation until AFR storage capacity can be implemented (30 minutes).
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2.
Cross-examination of these witnesses will alsc address the criticality hazards presented try cell venting to dissipate hydrogen gas build up, in addition to the explosive potential associated with such venting and hydrogen gas releases into the spent fuel pool building (estimated time of cross-exartiration:
2 hrs.)
B.
Deterioration of the spent fuel pool rack structure 1.
Cross-examination of the NRC staff and utility witnesses will address the unresolved safety problers associated with fuel design changes, inability to maintain proper boric acid concentration in the spent fuel pool and venting procedures which separately or in ccr6ination could result in total or partial rack failure (estimated tire of cross-examination: 3 hrs.)
C.
Qualification and testing of tFe boral raterial over a protracted period of time in a spent fuel pool envircre.ent.
1.
Cross-examination of the NRC staff and utility witnesses will address the insufficient and iradequate surveillance and fuel storage canagement procedures to assure that no significant deterioration in tra toral material occurs without prcrpt recognition of the hazard posed thereby and appropriate steps are i:rplerented 97 ci J_
J
In addition to the above arc 39 of cross-exaniration, the inte2Venors intend to explore, possibly both through direct tcstinony and cross-examination,the matters of ASLB interest pertaining to the Three Mile Island-2 accident and raised by the several limited appearance statmencs specified by the Board for consideration at these hearings.
Inasmuch as we are not in receipt of any proposed direct testimony pertaining to these issues filed by any other party to this proceeding, I am unable to prepare an outline of proposed cross-examination. Nonetheless, I anticipate that in light of the absence of such pre-filed direct testimony none is required j
under these circu:rstances.
Respectfully subnitted, CJ:r/
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n.ac u KEITH A. ONSDORFF Assistant Deputy Public Advocate tc.<rIFICATION OF SERVICE I hereby certify that copies of this outline of cross-examination have been served upon all parties to this action by deposit in the United States mail this 25th day of April,1979.
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p' KEITH A. ONSDJRFF
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